WQ0010286_Correspondence_19950221

State of North Carolina
Department of Environment,Y��VA
Health and Natural Resources IT
4 • �
Division of Environmental Management rr
—1
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary p E H N F =1
A. Preston Howard, Jr., P.E., Director
February 21, 1995
Ms. Gwen R. Kraus
Technical Services Manager for Product Marketing
Wheelabrator Clean Water Systems, Inc.
BIOGRO Division
180 Admiral Cochrane Drive, Suite 305
Annapolis, MD 21401
Subject: Permit Nos. WQ0010285 and WQ0010286
Baltimore I and NYOFCO Heat
Drying/Pelletizing Facilities
Distribution of Class A Wastewater Residuals
in the State of North Carolina
Dear Ms. Kraus:
The Division received your letter of February 1, 1995, providing comments from
Wheelabrator Clean Water Systems (WCWS) on the draft permits for the subject Class A
distribution programs. Each of the comments was taken into consideration in the
development of the final distribution permits, attached.
This letter is intended to help clarify the Division's position on each comment by
addressing each one in the order presented in your February I letter:
1. The subject condition (II.4.c) has been modified to require the following statement
in place of specific buffer requirements: "As with any fertilizer product, do not
apply in or near any water supply source or any body of water, including wells,
streams, rivers or lakes."
2. The Division's interpretation of the phrase "other container" is that it would include
truck beds, trailers, etc., to cover bulk distribution of residuals, as well. The
subject permits, however, have been modified to include the term. "bulk" anywhere
"bag or other container" is specified.
3. The Division's intention is to require WCWS to track the subject residuals only as
far as the initial recipient in North Carolina. The specified condition (UL2.b) has
been modified to better reflect the intended requirements.
4. For any given year that none of the subject Class A product is distributed in North
Carolina, a letter from WCWS which provides this information to the Division shall
be sufficient as an annual monitoring report.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

The Division appreciates the comments provided by WCWS and the cooperation
afforded during the review period. If you have any further questions on this matter, please
contact Mr. Ray Cox at [phone], Ext. 549.
Sincerely,
A. PresnHoward, Jr., P.E.
cc: Permit File WQ0010285
Permit File WQ0010286